Privacy policy

Last updated: 14 October 2026

1. Introduction

This privacy policy is intended to inform visitors and users of the fraamed.com website (hereinafter “Fraamed” or “the Site”) about how their personal data is collected, used, stored and protected.

Fraamed is a platform specialising in sports photography, particularly surf photography. It allows surfers to find, view and buy photographs taken during their sessions.

Respecting privacy and protecting personal data are commitments made by Fraamed, in accordance with the General Data Protection Regulation (GDPR – EU Regulation 2016/679) and applicable French law.

2. Data controller

The Fraamed website is a commercial product operated by the company:

• Company name: Redmoot
• Legal form: SARL (French private limited company)
• SIREN: 508 929 403
• Registered office: 33 avenue de l’Aquitaine, 64100 Bayonne, France
• Trading name of the service: Fraamed
• Website: https://fraamed.com
• Email address: contact@fraamed.com

Redmoot is the controller of the personal data processing carried out in connection with operating the Site, except for processing for which its service providers act as independent controllers.

Any question about data protection may be sent to contact@fraamed.com.

3. Personal data collected

3.1. Data collected when making a purchase

Fraamed allows users to buy digital photographs without creating an account.

When an order is placed, Fraamed collects in particular:

• The buyer’s email address.
• The references of the photographs ordered.
• The amount and date of the order.
• The information needed to validate and track the payment.
• The information needed for invoicing, where required.

The email address is needed to follow up the order, communicate with the buyer and send the information relating to their purchase.

Any other information required at the time of payment, including any billing details, is processed according to how the Stripe checkout is actually configured.

3.2. Payment data

Payments are processed by the specialist provider Stripe.

In this context, Stripe may collect the information needed for the payment, its security and fraud prevention.

Fraamed may receive information about transactions, including their amount, status, date and identifier.

Full card details are processed by Stripe and are not intended to be stored in Fraamed’s database.

3.3. Browsing data

When the Site is visited, certain technical data may be processed to ensure it works properly and securely, including:

• The IP address.
• The dates and times of requests.
• Technical information about the browser and device used.
• The data needed for the basket and the ordering process to work.
• Technical logs relating to the security and operation of the Site.

3.4. Data relating to photographs

Fraamed displays photographs taken during sports sessions, particularly surfing.

These photographs may show identifiable individuals and may therefore constitute personal data.

To make them easier to browse and search, photographs may be associated with information such as:

• The location where they were taken.
• The date of the session.
• The time they were taken.
• The type of sporting activity.

Photographs are publicly available in a watermarked form. The digital files offered for sale are delivered in accordance with the terms set out on the Site.

Fraamed does not use facial recognition or biometric identification to search for photographs.

4. Purposes and legal bases of processing

Personal data is processed for the following purposes:

Order management

Buyers’ data is used to process orders, manage payments and make the purchased photographs available.

Legal basis: performance of the contract.

Legal obligations

Some data is kept in order to comply with applicable accounting, tax and administrative obligations.

Legal basis: legal obligation.

Support and customer relations

Data sent by email is used to answer questions, handle support requests and manage any complaints.

Legal basis: performance of the contract or legitimate interest in responding to enquiries, depending on their nature.

Security and fraud prevention

Technical and transactional data may be used to protect the Site, detect fraudulent behaviour and secure payments.

Legal basis: legitimate interest in keeping the Site secure, or legal obligation, depending on the processing concerned.

Displaying and selling photographs

Fraamed organises and publishes the sports photographs in its catalogue so that they can be viewed and bought.

Where photographs show identifiable individuals, their publication and sale must rest on an appropriate legal basis under the GDPR and comply with the rules on image rights.

5. Photographs and image rights

The photographs offered on Fraamed are taken by Fraamed or its team.

They are taken during sporting activities, particularly at surf spots.

Some photographs may show directly or indirectly identifiable individuals, including minors.

Publishing photographs online and selling them are subject to the rules on privacy, image rights and personal data protection.

Requesting the removal of a photograph

Anyone who appears in a photograph may contact Fraamed to request its removal or to exercise their rights over their personal data.

Requests should be sent to: contact@fraamed.com

To help us process them, we recommend sending:

• The link to the photograph concerned or its reference.
• The approximate date and place where it was taken, if known.
• The nature of the request.

Fraamed examines each request in accordance with applicable regulations.

Additional verification of the requester’s identity may be carried out where there is reasonable doubt about it.

Removing a photograph from the online catalogue does not guarantee that copies already bought or downloaded by third parties will be deleted, but Fraamed handles the requests within its responsibility under the conditions laid down by law.

Photographs of minors

Photographs showing identifiable minors are subject to special protection.

Their publication and use must comply with the applicable rules, particularly regarding the consent of those with parental responsibility.

Legal guardians may exercise the rights relating to the minor’s personal data and image by writing to contact@fraamed.com.

6. Recipients of data and service providers

Personal data is accessible to authorised people within Redmoot, to the extent necessary for their duties.

It may also be processed by the service providers involved in running Fraamed.

OVHcloud — Hosting

The site, its database and its photographs are hosted on OVHcloud infrastructure, according to the services subscribed.

Website: https://www.ovhcloud.com

Stripe — Payments

Stripe processes payments and helps keep them secure.

Stripe may process certain data as a processor or as an independent controller, depending on the purpose of the processing.

Website: https://stripe.com

Brevo — Transactional emails

Fraamed uses Brevo to send emails relating to the operation of the service and to orders.

These messages may include order confirmations or the information needed to follow up a purchase.

Website: https://www.brevo.com

Other recipients

Data may also be disclosed to administrative or judicial authorities where required by law.

Fraamed does not sell its users’ personal data to third parties for marketing purposes.

7. Retention periods

Personal data must be kept for a period proportionate to the purposes for which it is collected.

Order data

The information needed to follow up an order is kept for as long as necessary to fulfil it, provide after-sales service and, where applicable, handle complaints.

Data subject to accounting or tax retention obligations is archived for the applicable statutory periods.

The accounting documents and supporting records concerned are in particular subject to a ten-year retention period.

Customer service data

Exchanges with customer service are kept for a period to be determined according to follow-up needs, complaints and the applicable limitation periods.

Technical logs

Technical logs are kept for a period proportionate to security, maintenance and diagnostic needs.

Photographs

The photographs are intended to form a catalogue of sports photographs that can be viewed over time.

However, photographs of identifiable individuals cannot be kept and published indefinitely, regardless of the purposes pursued and the rights of the people concerned.

Requests for erasure and objections are examined in accordance with the regulations.

User accounts

Fraamed does not currently offer user accounts.

If this feature is introduced later, the retention periods for accounts and their data will have to be defined and added to this policy.

8. Data security

Fraamed takes care to implement security measures suited to the nature of the data processed and the associated risks.

Payment security relies in particular on the use of Stripe.

The Site’s data is hosted on OVHcloud infrastructure.

Fraamed strives to protect data against unauthorised access, alteration, disclosure and loss, in particular through the technical and organisational measures actually in place.

These measures are adapted and reassessed as the service evolves.

9. Cookies and other trackers

Fraamed may use cookies and similar technologies needed for the technical operation of the Site and for processing orders.

These technologies may in particular be used for:

• The shopping basket to work.
• Securing the payment process.
• Temporarily remembering certain information needed for browsing.
• Keeping the Site secure.

Cookies that are strictly necessary to provide the service requested may be exempt from prior consent under the conditions laid down by the regulations.

Any audience measurement or advertising cookies, or other non-essential trackers, must be specifically assessed.

Where their use requires consent, these trackers may not be activated before consent is obtained. The user must then have a way to accept them, refuse them and withdraw their consent.

10. Electronic communications

Fraamed uses the email address provided when making a purchase to send information about the order and to follow it up.

These communications are necessary to provide the service.

Fraamed does not currently offer a newsletter and has not set up any dedicated consent collection for sending marketing communications.

If promotional emails or a newsletter are offered in the future, Fraamed will adapt its procedures and this policy to comply with the rules on electronic marketing, particularly regarding consent or the right to object.

11. Data transfers outside the European Economic Area

Fraamed uses OVHcloud, Stripe and Brevo, among others, to provide its services.

Although the Site’s main infrastructure is hosted by OVHcloud, some service providers may process data or allow access to it outside the European Economic Area.

Where such transfers exist, they must be governed by the mechanisms provided for by the GDPR, in particular adequacy decisions or the applicable appropriate safeguards.

12. Rights of data subjects

In accordance with the applicable regulations, anyone whose personal data is processed may exercise, under the conditions laid down by the GDPR:

• Their right of access to the data.
• Their right to rectification.
• Their right to erasure.
• Their right to restriction of processing.
• Their right to object.
• Their right to data portability, where applicable.
• Their right to withdraw consent where processing is based on it.

To exercise these rights, a request may be sent to: contact@fraamed.com

Fraamed responds to requests within one month, subject to any extensions permitted by law.

Data subjects may also lodge a complaint with the French data protection authority, the Commission nationale de l’informatique et des libertés (CNIL).

Website: https://www.cnil.fr

13. Changes to the services

Fraamed may develop its features, for example by offering user accounts, personalisation tools or a newsletter in the future.

If the processing of personal data changes, this policy will be updated to reflect the new practices.

Where required, users will be informed and their consent obtained before certain processing begins.

14. Changes to this privacy policy

Redmoot may amend this privacy policy to reflect changes to Fraamed, its service providers, its practices or the regulations.

The current version is available on the Site.

The date of the last update appears at the top of the document.

15. Contact

For any question about personal data protection, orders or requests relating to photographs: